This document describes what
information we collect from you, how we collect it, and how we use it to
provide the best gaming experience possible. It also describes how you can
control it and how we keep it secure.

1. Information Collected and Sources

Information received
directly from you

We may collect and store
information directly from you:

-When you use our games, you provide
to us a username chosen by you that will identify you as a player at our
social gaming network.

-When you use a game made by us for
the first time, we will create and assign to you an internalID
number. This ID number will be used internally at our apps to identify your
profile at the game you will be playing. This ID number may be displayed
publicly and used to build public links to your game profile.

-If you purchase our virtual currency
or virtual items, we will collect all information needed to process the
payment, such as billing information, credit card information, or any
other information needed if you process your purchase by a third-party such as
Facebook Credits or PayPal. Note that in this case, you may be subject to
additional policies from the third-parties. The email address you provide for
order processing may be used to send you information and updates pertaining to
your order, in addition to receiving occasional company news, updates, related
product or service information, etc.

-If you contact the customer
support team for assistance, we will collect and store all information
needed for the correspondence. This generally includes your name, email
address, ID number, and the info contained within the correspondence itself. We
also may collect information related with your activity on our services and
your game play. Your information helps us more effectively respond to your
customer service requests and support needs.

-If you subscribed for news at our
website, you may be asked to fill out a subscription form, where you
provide your name and email. We will store this information to keep you
informed and send news and updates. At the end of all emails received, you will
find a link where you can unsubscribe from this list.

Information received from
your computer

-When you use our services, we will
collect technical information about your computer such as your operating
system and version, browser version, IP address and the usage
statistics. This information will be stored at our servers on log files. We
continually strive to improve our website offerings based on the information
and feedback we receive from you.

-Cookies are small files that contain a small
amount of technical information in order to provide a more personalized
experience, such as keep you logged, and to analyze the usage of our sites and
services. The Service may place some of the cookies on your computer and linked
them to your internal user ID number.

-If you launch any of our games on a mobile
device, we may collect technical information such as your device type, and
unique device ID.

Information received from
the social networking website

If you are using our games
at a third-party social networking website such as Facebook, MySpace, or Google
+, we may collect information about you from your profile for that website
through its application programming interface. When you add (allow or accept)
our game on the third-party social networking website, you authorize Otherwind
to acquire and use this information in accordance with this Privacy Policy.
Notice that this information is affected by the privacy settings you establish
at the social networking website. As well, by using a third-party social
networking website you are accepting the Terms of Use and Privacy Policy of the
third-party website.

The information that we
may acquire from your profile at the third-party social networking website is
your first and last name, profile picture and its URL, your ID number at that
website, the ID number of your friends, your login email at that website, your
physical location, gender, and birthday.

On every one of our games,
you can always control if this information is publicly visible or not. This
information is only used to enhance the game play social experience of our
games.

2. Disclosure of your Information

We do not sell, trade, or
otherwise transfer your personal information to outside parties without your
consent.
This does not include trusted third parties who assist us in operating our
website, conducting our business, or servicing you, so long as those parties
agree to keep this information confidential. We may also release your
information when we believe release is appropriate to comply with the law,
enforce our site policies, or protect ours or others rights, property, or
safety.

3. Third Party Links

Occasionally, at our
discretion, we may include or offer third party products or services on our
website, such as links to a website or banner ads. These third party sites have
separate and independent privacy policies. We therefore, have no responsibility
or liability for the content and activities of these linked sites. Nonetheless,
we seek to protect the integrity of our site and welcome any feedback about
these sites.

4. Personal Data Protection

Our Privacy Policy is in
compliance with the local law where we operate, LOPD (Spanish Organic
Law 15/1999 of 13 December on the Protection of Personal Data). This is in
accordance with the European Union Data Protection Directive (Directive
95/46/EC), which regulates the processing of personal data within the European
Union. This law sets a high standard of protection and security level to
protect your information; you are protected under the laws under the EU laws
where this company was founded. We will not distribute your personal
information to outside parties without your consent, and it will not be used
for anything else other than to enable or enhance your gaming experience.

You agree that the
personal data provided by you may be processed in a data file owned by and
under the responsibility of Otherwind, duly notified to the General Data
Protection Register of the Spanish Data Protection Agency via the mechanisms
established for that purpose. Otherwind guarantees that all the personal data
provided by you will be used for the purpose, in the manner, and in line with
the limitations and rights granted by Organic Law 15/1999 on the Protection of
Personal Data (LOPD), and its implementing regulations.

By virtue of the
aforementioned legislation, you have rights of access, cancellation,
rectification and opposition of your personal data and withdraw of your
permission, without retroactive effect. If you want to exercise these rights,
please submit your request to privacy@otherwind.com.

5. Security of your Information

Your confidentiality and
the integrity of your information have a special importance for us. We
implement a variety of security measures to maintain the safety of your
personal information from accidental loss and unauthorized access, disclosure,
use and modification. However, there exists a remote possibility that hackers
can steal your information from us. As the transmission of information over the
Internet is not totally secure, we cannot guarantee the security of your data
while it is being transmitted to our site. Once we are receive your information,
we take reasonable precautions against possible security breaches but as no
website is completely secure, we cannot guarantee that unauthorized access,
hacking or accidental data loss will never occur.

If your account for a
third-party social networking website that you use to access to our games is
hacked, it may lead to an unauthorized play of our games, so we encourage that
you protect your login information. If you notice an unauthorized access with
your social networking website privacy department, let us know about this
unauthorized access by sending an email to privacy@otherwind.com.

6. International Transfer

If you are located in
other countries or regions outside the European Union, with laws governing data
collection and use that may be different, notice that you are transferring your
personal information to another country and jurisdiction that do not have the
same data protection laws as your jurisdiction, and you consent the transfer of
information to the European Union and the use and disclosure of your information
as described in this Privacy Policy. However, you don't need to worry; European
Data Protection Directive is one of the world's best protective measures for
your information.

7. Children's Privacy Protection

We are in compliance with
the requirements of Childrens Online Privacy Protection Act (COPPA). We do not
collect any information from anyone under 13 years of age. Our website,
products, and services are all directed to people who are at least 13 years old
or older.

8. Your Consent<

By using our site, you
consent to our privacy policy.

9. Changes to our Privacy Policy

If we decide to change our
Privacy Policy, we will update the Privacy Policy modification date at top of
this document.

10. Contacting Us

If you have any questions
regarding this Privacy Policy, you may contact us at privacy@otherwind.com.